Williams v. Orange County Jail
- Laura Swain
- 1:23-cv-00764
- U.S. District Court · Southern District of New York
- 4
In Williams v. Orange County Jail, Judge Swain dismissed Nayo Williams’s civil-rights complaint about stolen jail-account money and a denied grievance.
Nayo Williams’s federal claims against Orange County Jail and Keefe Commissary Network/Vendor were dismissed; the order also denied him permission to appeal without prepaying fees.
What happened
In Williams v. Orange County Jail, Nayo Williams alleged that another inmate used about $100 from his Orange County Jail account after staff gave multiple inmates the same password. He also alleged that officials denied his request to file a grievance.
The court dismissed both claims. It ruled that New York provides a remedy for the alleged property loss, and that there is no constitutional right to a prison grievance process or a particular investigation of a grievance.
Judge Laura Taylor Swain dismissed the complaint under the federal law governing lawsuits filed without paying fees. She also denied Williams permission to appeal without paying fees, finding that any appeal would not be taken in good faith.
The detailed version
- Williams v. Orange County Jail · No. 1:23-cv-00764
- Laura Swain
- Aug. 7, 2023
Background
Nayo Williams filed this self-represented civil-rights action under 42 U.S.C. § 1983 against Orange County Jail and Keefe Commissary Network/Vendor. He alleged that, while he was detained at the jail, about $100 was stolen from his inmate account and used on a vending machine without his knowledge. According to Williams, correctional staff had given the same password to multiple inmates who arrived at the facility at the end of August 2022. Williams said he reported the matter to correction officers, sergeants, and lieutenants, but they told him nothing could be done. He also alleged that officials denied his request to file a grievance and that he had not received a refund.
The court had previously separated these account-related claims from Williams’s claims concerning his arrest and opened this separate case. The court had allowed Williams to proceed without prepaying the filing fee.
Court’s analysis
Property-loss claim. The court dismissed Williams’s claim that money was taken from his inmate account. A federal due-process claim for the loss of property is unavailable when state law provides an adequate remedy. The court found that New York provides such a remedy and that Williams had not alleged facts showing that the state remedies were inadequate or inappropriate. Because an adequate state post-deprivation remedy was available, Williams could not state a federal claim that he was deprived of property without due process of law.
Grievance claim. The court also dismissed Williams’s claim that officials denied him the right to file a grievance. It explained that prisoners do not have a constitutional right to a prison grievance procedure, to have grievances investigated, or to receive a particular level of investigation. The court therefore concluded that this allegation did not state a claim for relief under Section 1983.
Disposition
The court dismissed Williams’s complaint under 28 U.S.C. § 1915(e)(2)(B)(ii), which requires dismissal of certain claims filed without prepaying fees, including claims that fail to state a legally valid claim. The court directed the Clerk of Court to enter judgment. It certified under 28 U.S.C. § 1915(a)(3) that an appeal would not be taken in good faith and denied Williams permission to appeal without prepaying fees. Judge Laura Taylor Swain signed the order.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.